121 added · 117 removed between the two most recent 10-Ks. The risks a company starts — or stops — disclosing are often the story.
Newly disclosed
For example, in January 2023, the White House’s Council on Environmental Quality (“CEQ”) released guidance to assist federal agencies in assessing the GHG emissions and climate change effects of their proposed actions under the National Environmental Policy Act (“NEPA”).
In September 2023, several states challenged the final rule in federal court alleging that the rule exceeds the EPA’s statutory authority under the Clean Water Act, and the litigation has been held in abeyance pending the administration’s review of the rule and litigation.
For example, generative AI systems may “hallucinate” producing inaccurate or misleading information, and model performance may degrade over time, leading to flawed recommendations.
In September 2025, the CEQ issued updated guidance and an updated template for NEPA implementation procedures to provide clarity to federal agencies and promote consistency in NEPA implementation.
During the fourth quarter of 2025, CNA was notified of a data breach impacting a vendor of a business associate of its current employee health insurance administrator.
You should carefully consider and evaluate all of the information included in this Report and any subsequent reports we may file with the SEC and the information we make available to the public before investing in any securities issued by us.
The potential for employees or third-party service providers, through intentional or inadvertent actions, to enable AI models to be trained on CNA’s data or its insureds’ data introduces risks of unauthorized use or disclosure of sensitive information and erosion of data privacy.
Boardwalk Pipelines’ cost and timing estimates for these projects are based on a variety of inputs such 28 Table of Contents as contractor indicative bids, quotes on materials and internally-developed financial models, metrics and timelines and are subject to a variety of risks and uncertainties, including obtaining timely regulatory and permit approvals and the cost thereof, adverse weather conditions during construction, its ability to acquire and the cost of obtaining rights to construct and operate on land not owned by Boardwalk Pipelines, delays in obtaining, shortages and price increases for key materials (including pipe, compressor stations and related equipment), tariff implications and shortages and increased costs of qualified labor.
In May 2025, the CEQ withdrew its interim guidance on considering GHG emissions and climate change under NEPA.
When new technologies, such as AI, are incorporated into CNA’s or its third-party service providers’ processes, they may introduce additional complexity and present greater risk to the effectiveness of these controls.
of this Report for additional risks associated with Boardwalk Pipelines’ growth projects and the related financing. 11 Table of Contents Boardwalk Pipelines’ more significant growth projects are listed and described below: Expected in-service date Expected incremental capacity added to system (Bcf/d) Eunice - Iowa (a) Third quarter 2026 0.1 Carnation Project (b) Fourth quarter 2027 0.2 Northeast Texas Power Plant Project (c) Fourth quarter 2027 0.3 Kosciusko Junction project (Kosci project) (c) First half 2028 1.2 Ohio Power Plant Project (c) First half 2028 0.3 Southeast Compression for Utility Reliability Expansion project (SECURE project) (c) First half 2028 0.3 Parks Line Upgrade and Sorrento Station Project (PLUSS project) (d) First half 2028 0.2 Texas Gateway Project (e) Second half 2029 1.5 Petal Gas Storage Expansion (f) Second half 2030 (f) (a) This project has received approval from FERC and is in construction.
In particular, the NGPSA and HLPSA were amended by the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (“2011 Act”), the Protecting Our Infrastructure of Pipelines and Enhancing Safety Act of 2016 (“2016 Act”) and, most recently, the Protecting Our Infrastructure of Pipelines and Enhancing Safety Act of 2020 (“2020 Act”), each of which imposed increased pipeline safety obligations on pipeline operators.
No longer disclosed
For example, in August 2022, the Inflation Reduction Act of 2022 (“IRA”) passed, which advanced numerous climate-related objectives, including a methane emissions fee that applies to excess methane emissions from certain facilities that starts at $900 per metric ton of leaked methane in 2024 and increases to $1,200 in 2025 and $1,500 in 2026 and thereafter.
For example, repairing Boardwalk Pipelines’ pipelines often involves securing consent from individual landowners to access their property, and one or more landowners may resist Boardwalk Pipelines’ efforts to make needed repairs, which could lead to an interruption in the operation of the affected pipeline or facility for a period of time that is significantly longer than would have otherwise been the case.
Additionally, in March 2024, the SEC released a final rule that establishes a framework for the reporting of climate risks, targets and metrics.
During the third quarter of 2024, CNA was notified of a data breach resulting from a ransomware attack that impacted a former vendor.
While the litigation is ongoing and the full extent and impact of these actions is unclear at this time, any disruption in Boardwalk Pipelines’ ability to obtain coverage under NWP 12 or other permits may result in increased costs and project delays if it is forced to seek individual permits from the Corps.
There may be additional risks that we do not yet know of or that we do not currently perceive to be material that may also materially adversely impact our business or the businesses of one or more of our subsidiaries. 17 Table of Contents You should carefully consider and evaluate all of the information included in this Report and any subsequent reports we may file with the SEC and the information we make available to the public before investing in any securities issued by us.
CNA has experienced, and may continue to experience, claim submissions and litigation related to denial of claims based on policy coverage, or the facts of the claim, in certain lines of business that are implicated by the COVID-19 pandemic and mitigating actions taken by its customers and governmental authorities in response to its spread.
The significance of such litigation or any other litigation relating to new or emerging variants of COVID-19 or other potential pandemics and related measures to mitigate the spread of the foregoing, both in substance and volume, and the resultant CNA-initiated activities, including external counsel engagement, and the costs related thereto, may have a material impact on CNA’s business, results of operations and financial condition.
CNA’s investigation into the incident revealed that an unauthorized third party copied some personal information relating to certain current and former employees, contract workers and their dependents and certain other persons, including some policyholders.
Litigation risks are also increasing, as a number of cities and other governmental entities have brought suit alleging that fossil fuel producers created public nuisances by producing fuels that contributed to global warming effects such as rising sea levels, are responsible for associated roadway and infrastructure damage, or defrauded investors or customers by failing to timely and adequately disclose adverse effects of climate change.
However, the future of the SEC climate change rule is uncertain given that its implementation has been stayed pending the outcome of legal challenges; moreover, the SEC under the Trump Administration may seek to repeal or revoke the rule, though Boardwalk Pipelines cannot predict whether such action will occur or its timing.
As a result, the ultimate impact of the SEC rule, or any similar climate-related disclosure requirements imposed in the future, on Boardwalk Pipelines’ business is uncertain and may result in increased compliance costs and increased costs of and restrictions on access to capital.